CODE OF CONDUCT
The Zinnwald Lithium Code of Conduct sets down 18 principles for appropriate ethical and professional behaviour and sets out the fundamental values that form the basis of and underpin all of Zinnwald Lithium’s business relaBonships.
Our Code of Conduct applies to all employees, officers and directors; and Zinnwald Lithium’s contractors and suppliers. We expect everyone to comply at all @mes with the principles in this code and people will be held accountable for their behaviour in rela@on to this code. Ac@on will be taken where this Code of Conduct is not followed, and consequences may range from a warning to dismissal or to cancella@on of a contract.
Senior management will monitor and review this policy on a regular basis to ensure that it con@nues to support and encourage a high standard of performance on our projects. The Board will make formal review of this policy every two years and update accordingly.
1.
COMPLIANCE WITH THE LAWWe are familiar with the basic legal requirements that apply to our du@es and responsibili@es. We are obligated to respect and observe the laws of the country in which we operate. Where possible, we will be given access to, and will have read, the opera@ng rules and regula@ons in appropriate procedure manuals. Where concerns arise, legal advice must be sought before any ac@on or decision is taken.
2.
HEALTH, SAFETY AND ENVIRONMENTZinnwald Lithium is commiJed to protec@ng the health and safety of its employees and the state of the environment. We comply with all applicable host country laws and regula@ons, in addi@on to our own policies and requirements.
We take personal responsibility to maintain a safe, healthy, and secure place of work. We expect everyone to deal with safety issues honestly and openly and always stop work if we think it is unsafe. Anyone repor@ng to work must be fit and ready to carry out their tasks, and be free from the influence of alcohol, illegal drugs or any medica@on that may impair their ability to execute their du@es safely and healthily. We iden@fy, manage, and report on poten@al environmental risks and seek to minimise our impact on the environment. We adhere to and comply with all relevant environmental legisla@on and the requirements set out in Zinnwald Lithium’s Policies and Standards.
3.
OUR WORKING ENVIRONMENTWe are an equal opportunity employer and any discrimina@on, harassment of bullying of any kind will not be tolerated. We do not discriminate, harass or bully any colleague or member of the public because of race (including colour, na@onality or ethnic decent), religion, gender, sexual orienta@on, age, or physical or intellectual impairment. All employees, officers and directors will be treated with equality during their employment, in all maJers, including employment, upgrading, promo@on, transfer, layoff, termina@on, rates of pay, selec@on for training and recruitment. We maintain a work environment free of discriminatory prac@ce of any kind.
Zinnwald Lithium’s key commitments are to:
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Provide clear and fair terms of employment.•
Provide clean, healthy and safe working condi@ons.•
Remunerate fairly.•
Encourage employees to develop skills and progress in their careers.•
Uphold our zero tolerance of any sexual, physical or mental harassment or any other bullying of our employees.Zinnwald Lithium expects everyone to:
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Comply with the leJer and spirit of the law.•
Maintain strict observance of company policies, rules and procedures including the repor@ng of improper or unethical behaviours (including any breach of this Code).•
Declare conflicts of interest and not let business dealings on behalf of the company be influenced, or appear to be influenced, by personal or family interests.•
Act with integrity at all @mes in a way that reflects Zinnwald Lithium’s commitment to upholding human rights, as outlined in the Zinnwald Lithium’s Policies.•
Never exercise or accept any form of exploita@on (within Zinnwald Lithium or its suppliers), including: inhuman treatment, child labour, coercion, forced labour, human trafficking and servitude, among other behaviours cons@tu@ng modern slavery.•
Respect company ownership of all company equipment, supplies, books, records and proprietary informa@on, including manuals and any other material.•
Not accept outside employment unless approved by the company.•
Not use informa@on or authority derived from employment with the company for personal gain.•
Preserve confiden@al company informa@on including customer lists, plans and decisions, informa@on about employees and any other informa@on that is not public knowledge. Confiden@al informa@on must not be used for personal benefit and must only be used in the ordinary course of business.•
Report to management any possible viola@on of any law or regula@ons.We respect the culture, heritage and customs in each neighbouring community in which Zinnwald Lithium operates and will never exert any improper, unethical or illegal influence over any individuals in communi@es affected by Zinnwald Lithium opera@ons.
We never make any commitment to communi@es without the proper authority and without recording the commitments in our site procedures.
5.
PROTECTION OF ZINNWALD LITHIUM’S INTERESTSWe strive to conduct ourselves with honesty and integrity beyond the test of legal legi@macy. We avoid ac@ons that compromise Zinnwald Lithium’s legi@mate interests or objec@ves. Specifically, bribery and corrup@on are not tolerated under any circumstances.
Zinnwald Lithium conducts its business in an honest and ethical manner and has systems in place to prevent bribery and corrup@on. Zinnwald Lithium does not tolerate any unethical behaviour from any stakeholder involved in its business.
6.
CONFLICT OF INTERESTEmployees who have served (or are currently serving as) directors or trustees of another organisa@on must, where that service poten@ally conflicts with Zinnwald Lithium’s interests (either commercially and/ or due to the @me required to fulfil the role), advise and seek approval from Zinnwald Lithium’s CEO, or where appropriate the Zinnwald Lithium’s Board. Employees should understand that they should not use their Group authority for poli@cal interests at any @me, or for community interests, when it has not been authorised by the Company.
Where poten@al exists for a Conflict of Interest in rela@on to a Joint Venture Party (JVP) and/or a Joint Venture (JV) the Employee and Zinnwald Lithium must act in accordance with the following protocol:
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The Employee will abstain from vo@ng on or making any decision in respect to the Joint Venture (JV).•
The Employee will advise the CEO if he or she believes at any@me that he or she may be the recipient of informa@on or document, which may create any poten@al conflict.•
The Employee will be given access to all informa@on or documenta@on of a general or opera@onal nature in respect to the JV.•
The Employee will be denied access to any informa@on or documenta@on that deals with any poten@al dispute between Zinnwald Lithium and the JVP.•
The Employee will be denied access to any informa@on, documenta@on or discussion that deals with the poten@al acquisi@on by Zinnwald Lithium of further interest in the JV or in the JVP or any other strategic transac@on involving either the JVP or the JV.•
If there is any doubt as to whether informa@on or documenta@on falls within any of the categories outlined above, the maJer should be referred to the Risk CommiJee and their decision will be final.her absence shall be detailed in the Minutes of that mee@ng.
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In the event that the Employee believes that the JVP has financial difficul@es that may impact on the JV or Zinnwald Lithium’s then he or she shall immediately disclose this informa@on to the CEO.•
The Employee will inform the JVP that Zinnwald Lithium has developed a plan for managing its poten@al conflict.•
The CEO will liaise with the Employee on an ongoing basis to ensure that any poten@al for conflict is closely monitored and avoided.7.
USE OF KNOWLEDGE AND INFORMATIONAccuracy, use and handling of informa@on is cri@cal to our integrity and reputa@on. Employees must ensure that they record informa@on honestly.
We never make improper use of knowledge, informa@on, documents or other Company resources obtained in the course of employment with Zinnwald Lithium. We respect the confiden@ality and observe the privacy of informa@on about the Company, its customers and fellow employees. The security and proper use of customer and Company informa@on is mandatory. We can disclose informa@on about Zinnwald Lithium that is specially designed and authorised for publica@on. All other informa@on about Zinnwald Lithium and its customers (including statements to the media) should only be released to legi@mately interested par@es, by those authorised to do so.
When handling confiden@al informa@on, we ensure that any papers or files are stored properly and not le^ in places that are visible. Informa@on should not be le^ on computer screens; employees should exercise care in conversa@on outside the Company, and never use this informa@on or other Company resources for private purposes.
We do not use confiden@al informa@on, or informa@on not publicly available about Zinnwald Lithium, for our own private gain or that of others. Shares in Zinnwald Lithium, or any other organisa@on to which the informa@on refers, cannot be bought or sold by anyone who holds confiden@al or inside informa@on that could affect the Company’s share price if that informa@on was made public.
The obliga@on not to misuse confiden@al or inside informa@on and to respect the privacy of informa@on will con@nue a^er employment has ceased. If any employees are in doubt they should ask their manager.
8.
ACTION WITHIN DELEGATED AUTHORITYManagement has a responsibility to inform all employees of the limits of their authority. When uncertain of their authority or of maJers rela@ng to policy, employees should seek clarifica@on from their manager. All employees are required to act within their delegated authority.
9.
STEALING OR MISAPPROPRIATION10.
GIFTSIt is cri@cal for Zinnwald Lithium that all staff, at all @mes, act without influence, and are seen to act without influence, in providing and contrac@ng services.
We do not seek, offer or accept any payments, gi^s, benefits or entertainment beyond that which is considered as normal, legi@mate business prac@ce. It is unacceptable to accept any gi^ when it can be perceived that the person offering the gi^ may derive a benefit if the gi^ is accepted. Such benefits may include favourable treatment or the alloca@on of more work to par@cular suppliers.
Clients and suppliers may offer small tokens of apprecia@on such as food and flowers or small hampers at Christmas @me. It is acceptable to receive gi^s of this nature if they are of nominal value and the gi^ is offered as a result of a genuine goodwill gestures.
If a gi^ is offered to someone that could be construed by others as improper, the offer of the gi^ must be reported to that person’s immediate manager. It is important to assess the value having regard to local customs and tradi@ons.
11.
PROFESSIONAL BEHAVIOURWe maintain the highest levels of professional conduct in our interac@ons with each other and in represen@ng Zinnwald Lithium in the community. Business rela@onships must be maintained in a manner that is consistent with the principles of respect for others, integrity and fairness and which meet, as a minimum, the laws applicable to behaviour in the work environment.
All forms of discrimina@on and harassment are prohibited.
12.
OUR BUSINESS DEALINGSWe are all responsible for Zinnwald Lithium maintaining the highest standards of ethical business conduct. Our key commitments to our customers are to:
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Act honestly and fairly in our rela@onships with customers.•
Provide products and services to the standards that have been agreed.•
Take all reasonable steps to ensure the safety of products and services we provide.•
Not engage in bribery or corrup@on in rela@on to our customers.Our key commitments to our suppliers and contractors are to:
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Act honestly and fairly in our business rela@onships.•
Not engage in bribery or corrup@on.•
Encourage suppliers and contractors to abide by the principles of our Code of Conduct.13.
RESPONSIBILITIES TO STAKEHOLDERSThe protec@on of stakeholders’ investment made in the company is paramount, as is realising superior returns on their investment. Zinnwald Lithium is commiJed to the honest, accurate and @mely communica@on to its stakeholders. No informa@on may be concealed from our auditors and no person may take ac@on to influence, coerce, manipulate, or mislead the Company’s auditors for the purpose of rendering the financial statements misleading.
Our key commitment to shareholders and the broader financial community includes:
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the exercise of the highest standard of care in preparing the company’s financialstatements;
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the delivery of shareholder value through sustainable and efficient opera@on of the company;•
the sound repor@ng and risk management prac@ces; and•
accurate and @mely disclosure.14.
USE OF COMPUTER SYSTEMSWe use computer facili@es appropriately. Unauthorised use, manipula@on or other interference will be treated seriously. For example, private passwords to computer files should be kept confiden@al and unauthorised access to confiden@al informa@on is prohibited.
15.
IMPLEMENTATIONAll Zinnwald Lithium directors and managers are responsible for promo@ng compliance with this Code of Conduct and monitoring its applicability and effec@veness. We are all responsible for complying with this Code of Conduct.
16.
BREACHES OF CONDUCTWe are all responsible for repor@ng any breach of the Code of Conduct.
Any breach should be reported to the appropriate manager. There may be occasions where it may be inappropriate to make a report to a manager or there may be concerns about reprisals if an allega@on is made. In these circumstances the maJer should be reported to the manager once removed.
17.
OBSERVANCE OF THE CODE OF CONDUCTZinnwald Lithium undertakes to make the Code of Conduct known and accessible to all employees, contractors and consultants. Its management will strive to ensure that all who represent the Company observes in word and in spirit the Code of Conduct.
18.
AWARENESS AND TRAININGThis Code of Conduct is available on the Zinnwald Lithium website. All employees are required to read and understand this Code of Conduct as part of their induc@on process.